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4. The only question to be considered is whether production of compound rubber on job work for the tyre manufacturing companies by the assessee amounts to "production of an article or thing"

qualifying for deduction u/s. 80IB of the Act. The Division Bench decision of this Court above referred is clearly on the point, though in the context of investment allowance u/s. 32A, because assessee in that case also was engaged in making of compound rubber for tyre manufacturing companies. This Court held that compound rubber is an article or thing produced by the assessee in their factory entitling it for investment allowance. We notice that section 80IB is worded in the same way as section 32A and therefore, the Division Bench decision of this Court squarely applies to the facts of this case also. It is also seen from the two decisions of the Supreme Court that Supreme Court has given a wide meaning to the expressions "manufacture or production I.T.A. No.288/C/2017 of any article or thing", occurring in section 32A, 80IB, etc. In the Sesa Goa Ltd.'s case (supra), the Supreme Court held that processing of iron ore amounts to manufacture or production of any article or thing. In N.C. Budharaja & Co.'s case (supra), the Supreme Court held as follows:

"The word "production" or "produce" when used in juxtaposition with the word manufacture" takes in bringing into existence new goods by a process which may or may not amount to manufacture, it also taken in all the by-products, intermediate products and residual products which emerge in the course of manufacture of goods."

What is made clear by the Supreme Court is that even production of intermediary products is sufficient to entitle the assessee for deduction available to new industrial unit. Compound rubber produced by the assessee on job work for the tyre manufacturing companies is an intermediary from which tyre is manufactured. If processing of iron ore which is only raw material for producing iron therefrom, amounts to manufacture or production of any article or thing, then we see no reason why compound rubber cannot be treated as an article produced by the assessee though for the tyre manufacturing company under contract. In other words, there is nothing in the section to indicate that article or thing produced or manufactured should be final product in itself. So much so, the activity of the assessee in their new industrial unit, which is mixing rubber with chemicals, process oil etc., making compound rubber, is covered by section 80IB of the Act. We notice that the Tribunal has disallowed the claim by following the decision of the Supreme Court in CIT v. K. Ravindranathan Nair (2007) 295 ITR 228. What was considered in that case was assessee's entitlement to treat processing charges received as part of export profit for the purpose of deduction u/s. 80HHC of the Act. We do not think the said decision has any application to the facts of this case. We therefore hold that assessee is entitled to deduction under section 80IB in respect of profit derived by the industrial unit where compound rubber is made."